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Section 1 Introduction

Publication 5258 — Guide for Affordable Care Act (ACA) Information Returns (AIR) Submission Composition and Reference Guide · 2026-10-03 edition · updated 2026-10-04 · United States

The ACA Information Returns (AIR) Project is responsible for delivering applications, infrastructure, and supporting processes required to process information returns. In January 2016, filing Forms 1094/1095-B and Forms 1094/1095-C became mandatory. Internal Revenue Service (IRS) will begin accepting TY2026 Forms 1094/1095-B and Forms 1094/1095-C, as well as original prior year forms and corrections, in January 2027.

AIR has two transmission methods: An Application-to-Application (A2A) channel and a Web Browser-based User Interface (UI) channel. AIR will perform structural and initial data validations on the information returns. Both the A2A and UI channels will also support requests for status responses (was the transmission accepted or rejected).

1.1 | Identification

The purpose of this document is to provide guidance to all types of external transmitters about composing and successfully transmitting compliant submissions to IRS. The audience of this document is:

  • Issuer – A business filing their own ACA Information Returns regardless of whether they are required

to file electronically (transmit 10 or more of the same type of information return) or volunteer to file electronically. The term issuer includes any person required to report coverage on Form 1095-B and any applicable large employer required to report offers of coverage on Form 1095-C and file associated transmittals Form 1094-B or 1094-C.

  • T.D. 9972 reduces the threshold from 250 to 10 and requires corrected information returns to be filed in

the same manner as original information returns.

  • Transmitter – A third-party sending the electronic information return data directly to IRS on behalf of

any business required to file. (Note: If you are transmitting returns for your own business, in addition to transmitting returns on behalf of another business, you do not need both the Transmitter and Issuer role. You can file all returns as a Transmitter.)

  • Software Developer – An organization writing either origination or transmission software according to

IRS specifications.

Issuers, Transmitters, and Software Developers are collectively referred to as transmitters throughout this document. Please note that not all transmitters are software developers and vice versa, but some of them can be both.

1.2 | Scope

This document covers details on composing and submitting Forms 1094/1095-B and Forms 1094/1095-C by transmitters to IRS. The scope of the document addresses the A2A-application based via SOAP messages exchanged between client and exposed Web Service endpoints and the Web UI-browser-based requiring human initiation. This publication is a living document that will be amended and updated each Tax Year/Filing Season and as deemed necessary.

When updates are made to the schema package for the A2A and UI channels, this publication will be updated accordingly.

Guide for ACA Information Returns Submission Composition and Reference Guide 2

Introduction

AIR accepts the following information return transmittals and documents for TY2017 through TY2026 in Processing Year (PY) 2027:

  • Form 1094-B, Transmittal of Health Coverage Information Returns

    • Form 1095-B, Health Coverage

    • Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information

Returns

  • Form 1095-C, Employer-Provided Health Insurance Offer and Coverage

AIR will process each submission, provide a status and detailed Acknowledgement for the Transmitter. Generally, the Forms 1095-B and 1095-C will be submitted with their associated transmittals, Forms 1094-B and 1094-C. However, in the case where a previously submitted and processed Form 1094-C, Authoritative Transmittal, requires a correction, the corrected Form 1094-C, Authoritative Transmittal, must be submitted alone without any accompanying Form 1095-C records.

1.3 | Purpose

The purpose of this document is to provide sufficient technical information to the transmitters so that they are able to compose and submit valid submissions comprised of Forms 1094/1095-B and Forms 1094/1095-C. The document addresses how the Receipt ID is transmitted from AIR to the Transmitter, as part of the synchronous session initiated by the Transmitter to submit the submission, and how the Receipt ID forms the basis for uniquely identifying Form 1094 and Form 1095 records within a transmission.

1.4 | Related Documents

Following documents are related with this guide:

Software Developers and Transmitter

Returns

Online documentation related to Forms 1094/1095-B and Forms 1094/1095-C are available at Affordable Care Act Information Returns (AIR)

Guide for Electronically Filing ACA Information Returns for Software Developers and Transmitters 3

Interface Overview

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▸Contents — Publication 5258 — Guide for Affordable Care Act (ACA) Information Returns (AIR) Submission Composition and Reference Guide

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